Legal

Privacy policy

How Xin Xin Homes handles personal data under Thailand’s Personal Data Protection Act B.E. 2562 (2019). This page describes what the software actually does today — including the parts that are not finished.

Last updated: 20 August 2026

This English page is the version a Thai lawyer read and confirmed. The Thai and Chinese pages are translations offered to make this easier to read, and no lawyer has checked them yet — so if a translated page and this one say different things, this English page is the one that applies. You can ask us for the English text at any time.

1. Who is responsible for your data

www.xinxinhomes.com and the media host media.xinxinhomes.com are operated as Xin Xin Homes. For the purposes of the PDPA, we are the data controller for the accounts, listings, bookings, leases and messages held on the platform.

What we cannot claim yet

The Thai company that will operate Xin Xin Homes is still being formed. The PDPA requires a controller to publish its identity and address, and a trading name is not that. The registered company name, registration number and registered address must be inserted here before this page is relied on.

Owners who list a home are separate controllers of the personal data they receive about their own tenants — the names, dates and payment details in their own lease. This page covers what we do, not what an individual owner does with what they learn.

2. What we collect, and why

Nothing below is inferred or bought. Every item is either typed in by you, produced by using the product, or captured as evidence for a document you signed.

Your account

  • Your name and email address. Email is the login identity — there are no passwords anywhere; you sign in with a one-time code sent to that address, or with Google, LinkedIn or LINE.
  • Whether you use the site as a renter, an owner, or both, and which of the two you last switched to.
  • A profile photo, if you upload one. ⚠️ Profile photos are stored in our PUBLIC media bucket by design — treat yours as public.
  • Your country, and whether you chose it or we guessed it from the network headers our host adds to your request; and your preferred language, if you set one.
  • The homes you save, and — if it ever happens — the fact that an administrator suspended your account and the reason recorded.

Why: to run your account, show you the right side of the product, and contact you about your own bookings and leases. Basis: performance of our contract with you, and our legitimate interest in operating a usable service.

Payment details you publish

  • If you are an owner: your PromptPay ID, bank name, account name and account number, and an uploaded bank QR image. You can save several and reuse them across your properties.
  • Whether the account name matches the name on your identity documents.

Why: so a tenant can pay you directly. Money does not pass through us — see the terms. Your payment details are shown to the tenant of a home once you have accepted their booking, and to nobody else; the bank QR image is served only to you and to that tenant.

Identity and ownership documents — sensitive data

If you choose to verify your identity, or to prove you own a home you are listing, you upload documents. We record which slot each file filled (document front, document back, selfie, or ownership document), its type and size, the decision, who decided it, and any note or rejection reason. Where a reviewer reads an owner name off a title deed, that name is recorded.

When a reviewer approves an identity check, they also record which kind of document it was and its number — your Thai ID or passport number. A Thai lease has to name both people by their document, so this is the number that fills in your contracts and that the signing record states we checked. You can see it on any contract you are preparing. If it is wrong, or you would rather be named by a different document, start the check again from your account: that erases the number we hold and you upload the new document.

The images themselves live in a private storage bucket that has no public address at all. They are never written under the website’s public files. They reach a browser only through a route that has already proved the viewer is you or a reviewer, and that route answers a stranger with “not found” rather than “not allowed”. Your user record holds no image — only the status, and, once you are approved, the document kind and number described above. A rejection stores no number, and starting the check again clears it.

Review is done by a person on our team, from a fixed list of reviewer email addresses set by whoever deploys the site. It is not automated, and no outside verification company is involved today.

Why: so the other side of a lease is dealing with a real, accountable person. Basis: our legitimate interest in preventing fraud on a platform where strangers hand each other keys and money, and — for the documents themselves — your act of choosing to upload them.

What we cannot claim yet

The back of a Thai national ID card shows religion, and religion is sensitive data under section 26 of the PDPA. A face photo is close to biometric data. Because of that, the upload asks for its own explicit consent, naming both, and records the exact wording, language, time, network address and browser details with the submission. While your documents wait for a reviewer you can withdraw from your account page, which deletes the photos immediately. If you would rather not show us religion data at all, cover or obscure that field before you photograph the card, or use a passport instead.

We log who opens your documents. Alongside the audit log of suspensions, role changes, unpublishing and payouts, every opening of an ID card, a passport, a selfie, a lease PDF, a chat attachment, a condition photo or a bank slip is recorded — who, what and when — by the route that serves the file, in a log nothing in the product can edit or remove. Ask us and we will read yours out to you.

These documents delete themselves. A scheduled sweep removes the images seven days after a submission is decided — from the object storage and the application disk both — and keeps only the decision. Withdraw before a decision and they go immediately. If storage ever refuses a delete, nothing is recorded as deleted and the sweep tries again rather than claiming a file is gone.

If you list a home

  • The listing itself — the public description, photos, videos and 360° panoramas, which are stored in the PUBLIC media bucket and served from our media domain.
  • The home’s full legal address, kept out of every public page and used only in the lease and in the owner’s own screens.
  • Coordinates, worked out on our server by following the Google Maps link you paste, and cached on the listing.
  • Private move-in instructions you write — wifi, electricity and water. These are released to a tenant automatically once the lease is signed and sealed, and to nobody else.
  • Your private notes about a property, which are only ever shown to you; your to-do list for it; and the brief you write for the AI assistant, which is deliberately marked as shareable with tenants and is read out to them by the assistant.
  • If you request our paid photo and video service: your name, email, the contact detail you type, and your note.
  • If you paste a description in through the “Already wrote this somewhere else?” door: the statement you agreed to (that the text and photos are yours to use), in which language, when, and the IP address and browser it was agreed from. This stays on the listing record and is never public. Contact details, links and other-site booking lines are masked out of the pasted text before it is saved, and you are shown what was removed.

⚠️ Photos are re-encoded when they are saved, which strips EXIF metadata including GPS. Videos are not re-encoded, so any metadata inside a video file you upload is published with it.

Bookings and viewings

  • Who requested which home, for which dates and term, and the amounts involved.
  • Your introduction message to the owner. Phone numbers, emails and messaging handles are masked out of it before it is stored — we never keep what you originally typed.
  • If a booking is cancelled: who cancelled, when, and the reason given. Reasons are masked the same way.
  • Viewings you book: your name, email, any note, whether you attended, and any cancellation reason.
  • Near the end of a tenancy, your one-word answer about renewing. It is written once and never changed.

Basis: performance of the contract you are entering, and our legitimate interest in preventing double-bookings.

Your lease — the heaviest record we hold

A signed lease is legal evidence, and it is treated as evidence. For each signature we store:

  • Your legal name as it appears in the lease.
  • Your Thai national ID number or passport number — these are quoted in the body of the lease itself, exactly as a paper lease would.
  • The time you signed, and the times the one-time code was issued and verified.
  • Your IP address and your browser’s user-agent string, captured at the moment of signing.
  • Either the signature you drew, stored as an image, or the name you typed.
  • The exact consent wording you were shown, and the language you were shown it in.
  • A snapshot of both parties’ legal details and the property’s legal address, frozen when the first signature lands.
  • Any comments either side wrote while negotiating, with the author’s name and email.

The finished PDF is sealed, fingerprinted, stored privately and emailed to both parties. It is served only to the two of you, and the route refuses to serve it at all if the fingerprint no longer matches.

Basis: performance of the lease contract, and compliance with Thai legal record-keeping — including the ten-year period in which a claim can be brought.

Moving in

The move-in condition record holds room-by-room notes, photographs of the property’s condition, opening meter readings, and a confirmation from each side carrying the confirming party’s legal name, IP address, user-agent, and the consent wording and language shown. The sealed PDF is fingerprinted like the lease. Photos live in the private bucket.

Rent

  • The bank transfer slip you upload, as an image, stored privately and shown only to you and your owner.
  • What our AI read off it: the amount, the date text, the receiving name, the last digits of the receiving account, and the transaction reference.
  • Which months an owner has confirmed as received, and how each was confirmed.

A month is only ever marked paid on evidence — a confirmation, or a matching slip. A past month with no evidence is shown as unrecorded, never as paid.

Messages

Chat runs between one tenant and one owner about one home. We store the message body after masking — phone numbers, email addresses and messaging handles are removed on the way in and the original is never stored — plus who sent it, whether the AI assistant wrote it, and per-side flags for read, present, archived, pinned and deleted.

Attachments are stored privately under a random name; we keep the original filename, type and size. Every image attachment is re-encoded when it is saved, which strips EXIF and GPS data.

What we cannot claim yet

Deleting a conversation does not delete the messages. “Delete” hides a thread from your inbox only. The messages are untouched, the other person still has them, and a new message brings the thread back. This is deliberate — the relay exists so both sides have a record, and a record one party can erase is not a record — and the product says so before you tap. Nothing in the product destroys a chat message.

Reviews

Scores and a written quote from each side, with the author’s and subject’s email addresses. Reviews cannot be edited by their author. An administrator can hide a review; there is no hard delete.

What our AI features record

  • Assistant questions and answers: the question is recorded after contact masking, with the answer, the outcome, the model used and where it was asked.
  • Search: your search sentence is recorded together with the filters we parsed out of it — with phone numbers, emails and messaging handles masked out BEFORE it is stored, the same rule your messages follow.
  • Photo scan: the owner’s email, how many photos were scanned, and the labels suggested. No image is stored.
  • Lease review: which contract, which owner, and every suggestion with whether it was accepted or rejected. Rejected suggestions are kept on purpose.
  • Translation: a cache of owner-written text and its translation.

These logs also serve as our rate limits, which is why they are written before anything is answered.

Technical data

Our host sees every request to the site, including your IP address, and supplies the country hint we store on your account. Loading a listing photo makes your browser talk to our media host; opening the map makes it talk to OpenFreeMap. A profile photo from a Google, LinkedIn or LINE sign-in is copied into our own storage once, the first time you sign in, and served by us from then on — your browser does not fetch it from Google, LinkedIn or LINE. Section 4 lists what each of those sees. While you are signed in, a page you have open tells us once a minute that you are still there, so we can see how much the site is really used; what is stored is a total of minutes per day, never what you were looking at.

3. Lawful basis, in plain terms

WhatWhy we may hold it
Account, listings, bookings, leases, condition records, rent recordsPerformance of a contract — with you, or the contract you are entering with the other party (PDPA s.24(3)).
Signature evidence: IP, user-agent, consent wording, ID numbers, timestampsEstablishing and exercising legal claims, and Thai record-keeping (PDPA s.24(4)–(6)). A lease with no evidence it was signed protects nobody.
Contact masking, rate limits, availability checks, audit log of admin writes, whether the emails we send you arrive, and a daily count of your time on the siteOur legitimate interest in a platform that works and is not used to defraud people (PDPA s.24(5)).
Identity and ownership documentsLegitimate interest in fraud prevention, and your act of submitting them. ⚠️ For the sensitive part of those documents, see the box below.
Service email about your own account, bookings, leases and rent — the message confirming your account is ready, the message confirming your own listing went live, and reminders to finish setting up your own account or listingPerformance of contract, and for the setup reminders our legitimate interest in an account somebody started actually working (PDPA s.24(3) and s.24(5)). The reminders are strictly about your own account or property. The automatic ones are capped: at most two about getting started and at most two about an unfinished home, and the last automatic one says so. A member of our team may also send you one of those same reminders by hand when your account or listing is waiting on a step — never anything promotional. Every one of them carries a link that switches them off, and that link is honoured whoever presses send. Service email about your account, a live booking, lease or rent cannot be switched off — that would be unsubscribing from your own tenancy.
News and offers from us, if you asked for themYour consent, given explicitly and separately (PDPA s.19). We never send these unless you ticked the box or answered yes when we asked, we hold the exact wording you agreed to, and one tap in your account page or at the bottom of any such email stops them for good. Nobody is ever emailed about somebody else’s property, and we sell no advertising and hold no list to anyone. The same rule applies to news and offers sent as LINE messages: only to people who said yes and have added our LINE official account.

What we cannot claim yet

What we record you agreeing to. Creating an account records your acceptance of these terms — the exact wording shown, its language and version, the time, and the network details — whether you sign up with an email, with Google or LinkedIn, or with LINE. Alongside it: the lease-signing and condition-record wordings (contract consent), the import warranty when you bring a listing description across, and the explicit data-processing consent recorded when you upload identity documents, which names the religion field and your face photo and can be withdrawn while the review is pending, deleting the photos immediately.

One thing we do NOT have: a separate consent on ownership documents — a title deed is not sensitive data in the way an ID card is, so it rides the same terms you accepted at signup. Marketing is different and has its own record: we ask, we store what you were shown, and an unanswered question means no. If any of that changes, this page changes with it.

4. Who else receives your data

These are every outside company the code actually talks to. There are no advertising networks, no analytics services and no data brokers — the product contains none.

WhoWhat reaches them
AnthropicOur AI provider. Six things are sent: a tenant’s question to a listing assistant (after contact masking) with the public listing facts and the owner’s brief; the last eight messages of a chat thread when the in-chat assistant is on (already masked); an owner’s listing photos for the photo scan; ⚠️ a tenant’s bank transfer slip image, which is NOT masked and shows the amount, date, receiving name, account tail and reference; ⚠️ lease facts for the AI contract check, which include the full property address and both parties’ names but never ID numbers; and your raw search sentence. Owner-written house rules are also sent for translation.
CloudflareObject storage. Every private file — ID documents, selfies, ownership documents, sealed leases, condition photos, chat attachments, bank slips, owner bank QR images — and every public file — listing photos, videos, panoramas, profile photos. Because listing photos are served from our media domain, ⚠️ Cloudflare also sees the IP address of every visitor who loads one.
MongoDB AtlasThe database. Every record described in section 2.
VercelHosting. All request traffic, including IP addresses, and the country hint we store on your account comes from them.
ResendEmail delivery. Recipient address, subject and the full body of every email we send you — including move-in instructions such as wifi details, one-click action links, and ⚠️ the sealed lease PDF as an attachment. A generic SMTP server can be configured instead, in which case that server sees the same.
Upstash (QStash)Runs our scheduled jobs by calling one endpoint on a timer. It receives no personal data at all — only the URL and the timing.
OpenStreetMap Foundation · OpenFreeMapTwo separate things. Our server asks OpenStreetMap’s Overpass service what is near a listing, sending the listing’s coordinates and not your IP. Separately, ⚠️ the map is drawn from tiles your OWN browser fetches from tiles.openfreemap.org — a DIFFERENT organisation, OpenFreeMap — so they see your IP address and the area of the map you are looking at.
freetsa.orgA timestamping authority in Germany. It receives the cryptographic hash of a sealed lease so it can certify when it existed — a fingerprint, never the document.
Google and LinkedInOnly if you sign in with them: we receive your email, name and profile image address, and store the email, name and which provider you used. The profile image itself is copied into our own storage once, the first time you sign in, and becomes your profile photo here — it is served by us from then on, not by Google or LinkedIn, and you can remove or replace it on your account page.
LINE (LY Corporation)If you sign in with LINE we receive your LINE user ID, display name, profile image address and, if you allowed it, your email, and we store all of them; the profile image is copied once at your first sign-in, as above. If you add our LINE official account or write to it, LINE tells us your LINE user ID and we look up your display name and profile image address so we can recognise you — that image is shown to our administrators straight from LINE’s servers, never copied. Messages we send you on LINE go through LINE’s Messaging API.
Google MapsOur server follows the short map link an owner pastes, to read the coordinates out of it. Google sees our server, not you.
LalamoveThe delivery company behind the moving-day price. Only when you tap “Show me the price”: your device’s location at that moment, your new home’s address and map position, and your move-in date are sent to Lalamove to price the trip. ⚠️ Your location is used for that one price and never stored by us. We never place orders and no money moves — booking and paying happen on Lalamove’s own site, under their terms.
Payment gatewaysBeam and Stripe integration code exists but has no credentials configured. ⚠️ Nothing is sent to either today, and no card details are collected anywhere in the product.
Automated ID checkingAn automated identity provider is built but switched off. It receives nothing today; all identity review is done by a person on our team.

Other people on the platform

  • An owner deciding your booking request sees a conduct-based profile: whether you are ID-verified, how long you have had an account, how many leases you have signed, and anonymised quotes from previous owners. They do not see your address history or which homes those reviews came from.
  • A tenant whose booking you have accepted sees your payment details for that home.
  • Reviewers on our team see, for anyone: email, name, roles, join date, suspension status and reason, verification status, and whether a payout account name matched.
  • Your first name and an initial appear on reviews you write.

5. Where your data physically sits

StoreWhere
Our application servers (Vercel)Singapore. This one is pinned in our configuration and is certain.
Database (MongoDB Atlas)Singapore. Read from the database provider’s own console on 20 August 2026.
File storage (Cloudflare R2)Asia-Pacific. That is the whole of what our storage provider tells us: it names a region, not a country, so your files sit somewhere in Asia-Pacific and we cannot honestly narrow it further. Read from Cloudflare’s own console on 20 August 2026.
Legacy files on local diskSome files written before we moved to object storage may still sit on the application’s own disk; the code still reads from there as a fallback. Any deletion we perform has to cover both places.

Some processing happens outside Thailand regardless: our AI provider, our email provider, the timestamping authority in Germany, and the map tile servers. Sending personal data abroad is permitted under the PDPA where it is necessary to perform a contract with you or at your request; we rely on that, and we keep the categories sent abroad as narrow as the feature allows.

6. How long we keep it

WhatHow long
Login and signing codesDeleted automatically the moment they expire. Stored hashed, never in the clear.
Upload permitsDeleted automatically after seven days.
Identity and ownership document imagesDeleted automatically SEVEN DAYS after the submission is decided — a scheduled sweep does it, from both our object storage and the application disk. The decision record is kept; only the photographs go. Withdraw an identity submission before it is decided and they go immediately, and the same sweep retries that deletion if storage ever refused it.
Your ID or passport number, once an identity check is approved⚠️ Indefinitely, while you stay verified. Starting the check again from your account erases it, a rejected check never stores one, and deleting your account removes it with the rest of your profile. Numbers already written into a signed lease stay in that lease.
Signed leases, condition records and their sealed PDFsTen years, the Thai claim period. For the sealed lease PDF this is now enforced by the storage itself: once a lease is sealed, our file storage refuses to delete or overwrite it for that period, so neither our software nor a mistake by us can quietly change or lose it. ⚠️ Honest limit: someone who can sign in to our storage account could remove that protection first. It guards against our own systems, not against us.
Chat messagesIndefinitely — a conversation is the record both sides rely on. If you delete your account, your name and email come off your side of every thread.
Accounts, listings and their photosUntil you delete your account (section 7): your profile, homes, media, ID documents and AI history are then erased, seven days after you ask.
Bookings, rent records, transfer slipsKept — they are the evidence of a tenancy and of rent that was paid, and they protect both sides. Deleting your account removes your name from what is not a legal or financial record, not the records themselves.
ReviewsKept, including after account deletion — the author then shows as “Former member”. Erasing reviews on the way out would let anyone launder their reputation.
AI logs — assistant questions, search sentences, photo scans, lease-review suggestionsIndefinitely, by design. Rejected lease suggestions are kept deliberately.
The IP and browser recorded with a listing’s import warrantyOne year from the warranty, then a scheduled sweep removes both of them together. The warranty itself — the words agreed to and when — stays: it is what answers a copyright claim about pasted text.
What you agreed to when you created your accountKept with your account: the exact wording, the language it was shown in, its version, the time, and the network details. It is the evidence that consent was given, so it lasts as long as the account.
Administrator action logIndefinitely. Append-only.
Document read log — who opened which sensitive file, whenIndefinitely. Append-only, like the action log — an access history that can be quietly trimmed is not one.
Emails we sent you — the address, the subject line, and what our mail provider reported back180 days, then the row deletes itself. It records that a message went out and whether it arrived; it never holds the body, and a sign-in code is masked out of the subject before the row is written. Erased with your account.
A daily total of the time you spent on the site while signed in180 days, then the row deletes itself. One row per day holding a number of minutes — not the pages you saw, not what you clicked, and no outside company is told. Erased with your account.
Your LINE contact record — user ID, display name, profile image address, whether you have added our official account, and when you last wrote to itKept while you have an account, and erased with it. For somebody who has no account, the record is deleted by a daily sweep 180 days after they last wrote to or followed our LINE account.

What we cannot claim yet

What deletes itself, and what does not. Login codes and upload permits expire on their own, and so do the email delivery log and the time-on-site count, after 180 days. A daily sweep enforces three further retention numbers in this table: identity document images (seven days after a decision), the network details on a listing import warranty (one year), and the LINE contact record of somebody with no account (180 days after their last message). Account deletion (section 7) is the one bulk erasure, and you start it yourself. Everything else in this table is kept until somebody removes it by hand — we would rather say so than publish a schedule we do not enforce.

7. Your rights under the PDPA

You have the right to:

  • Be informed about what we collect and why — this page.
  • Access your personal data and get a copy of it.
  • Have inaccurate data corrected, and incomplete data completed.
  • Have your data erased, or its use restricted.
  • Object to processing we base on legitimate interest.
  • Receive your data in a portable form and ask us to send it on.
  • Withdraw any consent you have given, at any time, without it affecting what was lawful before.
  • Complain to the Personal Data Protection Committee (PDPC) in Thailand.

What you can do yourself, today

  • Change your name, profile photo, country, language and whether you rent or list, on your account page.
  • Update or replace the payment details you publish.
  • Unpublish a listing, which takes it off the market.
  • Hide a conversation from your own inbox — noting that this does not delete the messages.
  • Remove individual photos from a move-in condition record, and delete a property task.
  • Download a copy of your data, from your account page — one file, assembled on the spot, with other people’s contact details left out.
  • Delete your account, from your account page. It runs 7 days after you ask (you can undo it in that week), and only once you have no live tenancy, booking or contract in progress. What the law makes us keep is described below.

What you have to ask us for

Write to privacy@xinxinhomes.com from the email address on your account. We will ask you to confirm it is you before we act.

What we cannot claim yet

Both of the big ones are self-service now — downloading a copy of your data and deleting your account both live on your account page, no email needed. What still goes through a person by hand: corrections we have no form for, and anything unusual. For those we cannot promise the PDPA’s 30-day turnaround with a straight face, but ask anyway, and we will tell you honestly where your request stands.

Some things we will refuse to delete, and you should know which before you ask. A signed lease, its signature evidence and its move-in condition record are the proof that protects both sides of a tenancy, and Thai law allows claims on them for years — we keep those for the retention period in section 6 even if you close your account. Chat messages are a shared record between two people, and we will not erase one side of a conversation the other party is relying on. Reviews can be hidden but not rewritten.

Complaining

If we get this wrong, please tell us first — but you do not have to. You can complain directly to the Office of the Personal Data Protection Committee (PDPC), Ministry of Digital Economy and Society, Bangkok.

8. How we protect it

  • Private files and public files live in two separate storage buckets with two separate credentials. The key that serves listing photos physically cannot read ID documents or leases.
  • Private files are never written where a web server can serve them directly. Every one goes through a route that proves who is asking first, tells browsers not to cache it, and answers a stranger with “not found” rather than confirming the file exists.
  • There are no passwords to steal — sign-in is a one-time code, and codes are stored hashed and expire.
  • Contact details are masked out of messages before they are stored, so what somebody typed is never on disk.
  • Uploaded images are re-encoded, which removes EXIF and GPS data.
  • A sealed lease PDF is fingerprinted, and the route that serves it refuses if the fingerprint does not match.
  • A sealed lease is written to storage that will not let it be deleted or overwritten for ten years. Draft leases are not — they are rewritten every time the document is revised before signing.
  • One-click links in emails are cryptographically signed, bound to one action, and cannot be replayed.

What we cannot claim yet

Document reads are logged. Every time somebody opens an ID document, a lease PDF, a chat attachment, a condition photo, a rent slip or a bank QR, the serving route writes an entry — who opened it and when — that nothing in the product can edit or remove. It is how “who looked at my passport?” gets an answer. Ask us and we will read yours out to you.

9. Children

The service is for people who can enter a tenancy agreement in their own name. We do not knowingly collect data from anyone under 20 without a guardian’s involvement, and the product has no age check. If you believe a minor has an account, write to us and we will deal with it.

10. Changes

When this page changes, the date at the top changes with it. Because the product is still being built, expect this page to gain more than it loses — and expect the yellow boxes to disappear one by one as the gaps behind them are closed.

Questions about this page

Write to privacy@xinxinhomes.com. The other pages in this set are privacy, terms and cookies.